Commercial Long XC Question (# of Airports)

Discussion in 'Pilot Training' started by Skid, Mar 18, 2019.

  1. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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    I said that I would not log it as *I* don't considerate one flight but two separate lights.. I also don't sign off my students until they demonstrate proficiency to the standards above the certificate they are going for. If they are going for private they have to fly to commercial standards before I sign them off. If they're going for commercial they have to fly to ATP standards before I sign them off.
     
  2. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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    I would refer to it as an around-the-world trip but I would not refer to it as an around-the-world flight.
     
  3. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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    When we are together I start stopwatch when we take off. When they are on their own I tell them what the logging rules say and what I would prefer but I don't babysit them. Yeah I may have shorted myself a hundred hours or so by not logging as soon as the engine starts and I creep forward before doing the brake check but I also know that my flight time is actual time in the air.
     
  4. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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    in a particular situation I mentioned about my student he's first point of landing was a hundred miles away. So it was a cross-country no matter what happened on the way back. I didn't go against anything. The sitting on the ass is letting the engine run for 2 hours on a ramp somewhere telling me this flight time. I never okayed an overnight this was a pre private student on his first solo XC. And technically I'm not sure I can approve or sign off a student for an overnight since the logbook signature says a date that it is being done on.
     
  5. TCABM

    TCABM Cleared for Takeoff

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    This isn’t about you per se. If the intent to fly starts at taxi, that .1 or .2 you’re not counting for your student (on dual flights) adds up over time and can result in an extra 2 or 3 hours of aircraft rental for the student and depending on how you charge for your time, income for you.

    Or am I not understanding your method?
     
  6. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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    I'm not doing instruction to make money. So for me the hours don't matter. Some lessons I tell them not to even worry about payment. My past and current students own their own airplanes (or had a fuel only deal worked out with the owners) and don't care about hours so rental time isn't an issue either.
     
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  7. Lindberg

    Lindberg En-Route

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    There's no cutoff. If the aircraft moves under its own power for the purpose of flight, it counts as flight time until it comes to rest. That's it. Could be ten minutes, could be ten hours. In between, it's flight time. How you choose to log your time is interesting, but that doesn't mean it's correct or that anyone else is cheating. The fact is that you are logging less than you're entitled to.
     
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  8. ja_user

    ja_user Pattern Altitude

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    I assume no one would have a problem flying at 40% power to save fuel, or taxiing slow...

    But I agree. if you are really just sitting on the ramp letting it idle, what is the point?
     
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  9. IK04

    IK04 Cleared for Takeoff

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    Was the commercial qualifying long cross country always a solo requirement? I kinda remember having a pilot friend with me to keep me awake...

    My Flight was an all-night affair that was composed of stops at four airports and began at around five pm and ended a little after dawn the next day.

    I don't know who would ever think that the whole flight would have to be done in the same calendar day.
     
  10. Matthew Rogers

    Matthew Rogers Pre-takeoff checklist

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    Not 24 hours, but I had 1.5 hours where I was trying to get airborne and three frozen pitot tube incidents (and three heat guns later) and aborted takeoffs, lots of taxiing around and run ups. I counted those hours because they all involved pilot skills required for flight and I certainly wanted to get up in the air. I did eventually get to fly all for the purpose of going 10 miles away to bring my plane to the AP.
     
  11. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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    As long as I've been flying it's been solo requirement (the new stupid CFI ride along allowance notwithstanding). Sounds like yours was all one flight. I never said flying past midnight was verboten. That was a strawman set up by someone else trying to attribute that to me.

    I personally wouldn't have counted that, but I've never been trying to build generic hours towards any ratings.
     
  12. flyingcheesehead

    flyingcheesehead Touchdown! Greaser!

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    See, that one I'd disagree with. You're not taxiing for the purpose of flight, you're taxiing to relocate the airplane to the fuel pump. When you start taxiing AFTER filling up, then it's for the purpose of flight (unless you're just going back to the hangar).
     
  13. Juliet Hotel

    Juliet Hotel Cleared for Takeoff PoA Supporter

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    I stopped caring about logging long ago so no dog in this race for me. But this is an easy one to swing at so I'll go ahead and swing.
    Question: Why did you go to the airport? Was it to go flying or was it to fuel the plane and possibly do other stuff like washing the plane but not to actually fly it? If you left the house to go to the airport with the intention of going flying, then it stands to reason that when the plane moved to go to the fuel pump, it was moved with the intention of flying.

    Let's frame it another way. Let's say you're on a long XC. You need to stop for fuel and lunch. You land and taxi to the greasy spoon and have lunch. After lunch you taxi to the fuel pump and top the tanks. Do you write down or otherwise keep accurate track of that taxi time so you can subtract it when you sit down to log everything at the end of the day?

    No one is going to argue with you if you choose not to log the taxi time to the pump. But to be fair, no one at the FAA is going have an issue with it if you log taxi time to the pump and I suspect extremely few bother to subtract it out.
     
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  14. flyingcheesehead

    flyingcheesehead Touchdown! Greaser!

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    I think they would have an issue with it. When you shut down the plane and get out of it, there is no longer any part of it moving under its own power, and you never intended to take flight when you started it up. I don't know that there's an official interpretation on this yet, though.
     
  15. Juliet Hotel

    Juliet Hotel Cleared for Takeoff PoA Supporter

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    So you're going for the most literal interpretation of the official definition of flight time. That's certainly a noble undertaking but it does make me wonder something. When you land and you're taxiing in, if you happen to have to come to a stop for any reason, holding short of crossing runway for example, do you stop the clock right there or do you wait until you shut down to note the ending time for the flight?
     
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  16. flyingcheesehead

    flyingcheesehead Touchdown! Greaser!

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    No... Nor do I stop the clock for the runup or any stops on the way to the runway, because at least I am in the airplane, in command of the airplane, and parts of the airplane are moving under their own power.

    If we're not supposed to take the FARs literally, how are we supposed to take them? :dunno:
     
  17. apr911

    apr911 Pre-takeoff checklist

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    This is an interesting conversation and one that the FAA is incredibly vague on. Interpretation after interpretation (such as those listed in this thread and others such as Van Zanen) have repeatedly left logging of flight time to the discretion of the pilot.

    Its one that I recently struggled with as I worked my way through my old log book, digitizing each flight. I used multiple log lines for flights for airports as few as 6.5NM apart while in other places, I had 3 (A->B->A), 4 (A->B->C->A) or more airports logged in a single line.

    Meanwhile, my commercial XC was logged as 4 separate lines because leg had detailed notes on the route flown including some really Airports that I wanted to "immortalize" in my log. Things like landing at an operating space port and aircraft bone yard, shooting the Trona Gap in a minimally equipped airplane based almost entirely on DR and Pilotage, landing at the lowest airport in North America before taking the plane to the very edge of and beyond its specified service ceiling in order to get over some orographic clouds while crossing the Sierra Nevada's at nearly 14,000ft...

    Some of these were more cut and dry. My Commercial XC? Pretty straightforward... Sure I logged it on 4 lines but that was more because of the detail involved than anything else. While I did have a "ground stop" at each airport with engine shutdown, the first leg was a fueling stop and to double check weather for my 2nd/3rd legs I was on the ground maybe 30 minutes. On the second stop I hopped out of the plane, took some pictures and was back in the plane taking off for leg 3 maybe 20 minutes after shutdown and the third stop was a food/fuel stop (skipped lunch, ate snacks enroute) that lasted about an hour and half which was after extending it by 15 minutes on the ground (and 15 minutes flying laps around the pattern) to give a developing line of fast moving coastal storms time to move into the area of my destination, knowing they'd move out by the time I got there 2-ish hours later. Total flight time came in at 7.3 hours with straight line distances of 146.1NM, 104.4NM, 163.3NM and 261.1NM and a total of 756NM as flown.

    Others were more complicated... Such as the flight I did as a student pilot from A->B->C all within 50NM of A, at C my instructor got out and I solo'd (controlled airport landings), the instructor than got into the plane again and we flew from C to D 51NM away before returning to A. Where things got interesting was in how my instructor logged it...

    Line 1 was Logged A->B->C as 1.6 with 1.3 Dual and 0.3 Solo
    Line 2 was Logged C->D as 0.9 Dual XC
    Line 3 was Logged D->A as 0.4 Dual, NO XC.

    So my Solo flight wasn't logged as a separate flight, yet for some reason C->D was a separate flight... No matter, Van Zanen et al. say I could consider A->B->C a repositioning flight and log C->D as XC even if my instructor didn't get out of the plane and I didn't have a separate "flight" solo and since there was in fact a separate "flight" in there adequately described in the description as "Solo Pattern work at Airport C" even if it wasn't logged separately, it would seem pretty obvious...

    But what about C->D->A? The FAA and the various interpretations say I could log all of the time from C->D->A as XC even though A wasn't 50NM from C or D since I had 1 leg that was over 50NM so why did D->A constitute a different flight from C->D when A->B->C and Solo work at C did not? Hurts my head.

    My general rule is any time the "condition" of flight changes (taking on, off-loading or changing passengers, day-to-night or vice versa, change of airplane, etc) or is interrupted by a ground stop exceeding the number of flight hours spent getting to the stop, at a minimum of 1.5 hours up to a maximum of 8 hours, it gets logged on separate lines. Whether it constitutes another flight or not depends more on the stated "purpose" of the flight overall and even so 50NM really isn't all that far so I try not to put myself in a position where a leg that could conceivably be considered a separate flight and doesn't go more than 50NM from the point of origin of that flight.

    To me, 50NM is the only number that really matters since its the required distance for XC Aeronautical Experience for PPL, IRA, CPL and ATP (though landing is not required for ATP, just flying further than 50NM). For Part 135, they take the far more liberal FAA definition of XC time as any flight that travels to an airport other than the one from which you took off.

    Which really just means none of the conversation being had about whether it constitutes one flight or multiple flights really matters in most instances. It applies to only the 6 XC's (less if you combine them 1 or more of them) that are part of the PPL, IRA and CPL ratings which specify XC's of specifically defined distances and number of stops. The conversation will matter less and less as you accumulate XC time beyond those 6. When I completed my CPL XC, the "specified distance XC's" for PPL (150NM + 100NM Night), IRA (250NM Routed) and CPL (300NM + 2x 100NM) accounted for 20 hours which was more than a third of my total XC time to that date. Today, its less than a 20% and only decreasing further with each additional XC I do.
     
  18. Juliet Hotel

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    So you're against logging in violation of the regs before takeoff, but you're ok with logging in violation after landing. Got it.
     
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  19. Ryanb

    Ryanb Final Approach PoA Supporter

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    Well to be fair, @flyingcheesehead does have a point.

    Flight time means:

    (1) Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing

    Although taxi time can technically be logged, if you’re not intending to actually go fly (ie., taxiing to the fuel pumps ONLY) than per the reg, you really shouldn’t log it as flight time. After the flight has completed, the taxi time back to the hangar CAN be logged legally. In this instance, I agree with his reasoning.
     
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  20. IK04

    IK04 Cleared for Takeoff

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    As fast as I see people landing, it should be easy enough for them to shut off the engine on touchdown and coast in to parking or fuel...
     
  21. apr911

    apr911 Pre-takeoff checklist

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    Not arguing that it means you can take a passenger but I always found the CPL XC of 300NM to be a bit of an oddity. Its the only XC of a defined distance that, with a few exceptions, cannot be completed as a round-trip flight in the minimum total distance defined and has restrictions not consistent with the pilot's license.

    The PPL Night Dual XC says 100NM total distance of XC with a stop more than 50NM, so you can complete it in 100NM exactly.
    The PPL Day Solo XC says 150NM total distance with at least 1 stop of more than 50NM, so you can complete it in 150NM exactly. It must, by necessity and independent of the term solo used in the regs, be completed solo since the student pilot is not permitted to carry passengers and would not be able to log PIC time with a CFI onboard.
    The IRA Dual XC says 250 NM routed, which could technically mean you never even have to leave the 50NM area from the local airport.
    The CPL Dual Day/Night XC both say only a single one-way leg of 100NM which implies a minimum distance of 200NM but both can still be completed in 100NM exactly when both are flown, as they typically are, as part of the same round-trip XC (day on the outbound leg, night on the return leg).

    The CPL 250/300NM XC though cannot be completed in 300NM. In fact it cant be completed in less than 500NM roundtrip... If you fly 250NM North A->B, then fly 50 NM South B->C, you meet the requirements but still need to go another 200 NM to get from C->A.

    I've also always found it odd that they require it to be Solo, as in the sole occupant of the plane. Wouldn't it be more likely for you to have passengers on a long xc such as that? Why as a certificated PPL am I subject to an artificial limitation that does not actually exist on my license for the purpose of this operation? Wouldn't a distracting environment with passengers be closer simulation of a real world commercial cross country? I guess the argument there is that the intent is to demonstrate SRM but again isnt CRM more inline with more (I know, not all) of the commercial pilot jobs out there? For that matter though, why does the FAA trust us as pilots to log our time how we see fit and do a host of other things (such as not instruct without a CFI) but will only trust a CFI for a ride-along? Why cant 2 pilots go out with the agreement that the second pilot is to be a ghost in the right seat (or even rear)... This way 2 pilots could trade off and complete their CPL XC in the minimum time without one of them having to drive or fly out commercially.

    Just some thoughts I've always pondered... None of which should be construed as supporting an attempt to complete the requirement at the absolute specified minimums, just an observation/discussion on how the FAA determines those minimums.
     
    Last edited: Mar 22, 2019
  22. flyingcheesehead

    flyingcheesehead Touchdown! Greaser!

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    How am I logging in violation of the regs at any point? I log starting "when the airplane moves under its own power for the purpose of FLIGHT", and ending when it "comes to rest after landing". If the engine is still running, it's not at rest.

    Barring an interpretation to the contrary, my general rule when it comes to the FARs is purely based upon my own honesty: If I had an inspector look at me and ask "why did you do X?" I want to be able to plausibly defend against an accusation that I broke the reg in question. In this case, I can't in good conscience say "well, I was going to go fly later, so it should count!"

    The plane is back "at rest" while you're fueling, and at no point in between when it first "moved under its own power" and when it came back to rest did you intend to fly. So, not loggable.
     
  23. Juliet Hotel

    Juliet Hotel Cleared for Takeoff PoA Supporter

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    Says who? The official definition of flight time does not say "all time from when the engine starts with the intention of flight...' It says when the plane moves. Doesn't really seem unreasonable then to believe that if the FAA wants us to mark the very moment the wheels start turning as the start of the flight time, they would also use the wheels stopping after landing as the moment when flight time ends. Taxi off the runway and stop for any reason and boom, flight time over. From that moment on, the wheels are no longer turning with the intention of flight, they're now turning with the intention of finding parking.

    To be clear, I do not define flight time in this way nor am I saying anyone else should.The point is there is a fair amount of gray built into the FAA's definition. There are lots of individuals, myself included, who not think twice about logging tach time or hobbs time from motor start at the hangar until motor stop back at the hangar including taxiing for fuel because when they pulled the plane out of the hangar they did so with the intention of going flying. And I would further say that if there is an FAA official out there who would cite a pilot in violation for logging in this way, then the FAA needs a budget cut because they've got employees with way too much free time on their hands.
     
  24. apr911

    apr911 Pre-takeoff checklist

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    You* get into some really weird scenarios trying to follow the letter of the FAR's.
    Safety issues aside, you could in theory start your engine, taxi to the fuel pumps, keep the engines running, refuel and go flying and meet the FAR requirement of moving under its own power for the purpose of flight and your definition that the plane is not at rest while the engine is running... But wait! Even if we drop that definition and say while the engine was running the plane came to rest and is at rest anytime it comes to a complete stop... how can I log time?

    Ok... so then you can Start the engine, taxi to the runway, doing run-up during taxi, take off, do a lap around the pattern land, continue the ground roll to the fuel pumps before killing the engine... Refuel, hop back in the plane, restart and taxi for takeoff before continuing on the planned flight and log all of my time as "moving under its own power for the purpose of flight until the plane is back at rest" as long as you never let the plane stop rolling.

    The issue also has a whole bunch of other oddities that can be applied... If the fuel pumps are in the direction which you need to go to reach the runway, what portion of the motion to the fuel pumps is for the purpose of getting fuel and what portion is intended for the purpose of flight? You're not going to start your engine, taxi to the fuel pumps, stop & refuel and then taxi back to parking just so you can confirm that all time logged was "for the purpose of flight" are you?

    Of course if the fuel pumps are on the opposite side of the field than you might have a point but even in that case you should only "lose" the portion of the taxi from parking to the fuel pumps... The return trip past parking to the other side of the field is "taxiing for the purpose of flight."

    Ultimately, it begs the question to what end does it really matter? In most places your taxi to fuel is likely going to be <6 minutes which is less than 0.1 on the hobbs which only measures in tenths of an hour. In other words, its a non-significant digit. Maybe if you were at DFW and had to taxi from 35R to 13R which could conceivably take 6 miles and 2 hours at a CDC defined fast walk of 3-4 mph (does anyone actually taxi at that speed?) it would be a significant difference but that's normally why larger airports are designed with the ramp being located somewhere near the center of the field.

    DFW is designed this way, so taxing to the fuel pumps would be "enroute" from 35R to the departure runway of 13R so almost all of those 2 hours on the ground taxiing at DFW could be the for "the purpose of flight" even with the stop. Of course, you'd realistically never have to make such a long and arduous taxi journey.

    As to abuse? There will always be someone who tries to abuse the system. Rules are usually put in place to curb the most excessive and blatant abuses but once a rule has been established and written down, it defines what is "technically" acceptable and there will always be someone who tries to test the boundary of the definition of legal. Language lacks sufficient descriptive power to adequately define all scenarios. That's usually how new rules or in the case of the FAA, interpretations, come about... Someone trying to work the system to their advantage (or rat out someone working the system to their advantage). Its also how most scandals come about, getting caught doing something within the bounds of the law but which nobody else considered such an application (the size of the scandal often is directly proportional to the cognitive dissonance exhibited and the population that failed to consider the implication... i.e. the NSA spies on allied foreign leaders?!?)

    I find it particularly funny that a person** who made a moderately personal rebuke of my own application of a "legal intent, erring in the direction of safety" based definition of a term not explicitly defined by the FAA though implicitly accepted as part of the international is making their own "intent" based argument here to support their own methodology of logging time. Arguing "flight time" is only the time while the plane is in the air is inconsistent with the explicitly defined definition of flight time by the FAA as "when an airplane moves under its own power for the purpose of flight and ending when it comes to rest after landing"


    *Note: I use "you" in the broadest sense possible not as a personal point of contention with what @flyingcheesehead said. The included quote however does help highlight the absurd realities of the FAR.
    **Also not flyingcheesehead.
     
    Last edited: Mar 23, 2019
  25. flyingcheesehead

    flyingcheesehead Touchdown! Greaser!

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    Actually, I believe that there ARE legal interpretations to that effect from the FAA Chief Counsel. I'll let someone who knows how to search those help out here... Or teach me how. ;)
     
  26. Wheels

    Wheels Pre-takeoff checklist PoA Supporter

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    The rest of the FAA might see it that way but the Chief Counsel’s Office definitely doesn’t.

    “In a 2004 interpretation issued to Randall C. Kania, the FAA explained that once flight time commences, it continues to accrue as long as the pilot is required to remain onboard the aircraft. Thus, an aircraft does not come to rest after landing while the flightcrew is required to remain on the aircraft.”
    https://www.faa.gov/about/office_or...016/johnson - (2016) legal interpretation.pdf
     
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  27. Jim_CAK

    Jim_CAK Pre-takeoff checklist PoA Supporter

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    I have been working on my commercial after nearlly 20 years of flying. When I read 61.129 I was also puzzled by the requirements of dual on the 100nm XCs and sole occupant on the long XC. After doing the dual XCs with a CFI - I realized that I had not been on an XC with an instructor since my instrument rating - 15 years earlier. The CFI had some good insights and it was worth while being dual. The only explanation for being sole occupant I ever read on the long was so you could demonstrate you could manage the entire flight without anyone helping. Even a passenger can help hold charts or get something out of your reach. I guess it is good prep if you are going to be a future freight dog flying alone on those dark and stormy nights.
     
  28. IK04

    IK04 Cleared for Takeoff

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    Hmmmm... Every bit of my civilian flight time was based simply on Hobbs time. Consideration for taxiing for fuel or parking was never a thought. In 5,000 or so hours, that would only add up to maybe 10 hours, so who cares?

    The only important concern with whether an operation is considered for the "intent to fly" is for accident investigation purposes...

    When applying for a part 135/121 Operation job, they will (usually) factor military helicopter time by 1.2 because it is logged from liftoff to blades stopped.
     
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  29. midlifeflyer

    midlifeflyer Final Approach

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    Not sure how much that helps. You cantaxi off the runway onto the ramp and then turn the airplane over to a non-pilot, who can taxi all over the place.
     
  30. WannFly

    WannFly En-Route

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    Can we just log the Hobbs hour and be done with this?
     
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  31. Ryanb

    Ryanb Final Approach PoA Supporter

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    It can’t be that simple!
     
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  32. ja_user

    ja_user Pattern Altitude

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    The commercial solo xc can be done in 1 301nm flight. Nothing says you have to return to the destination, or can’t pick up a passenger/Cfi, etc. just log the flights appropriately. It’s also the only requirement that really make sure you can plan a trip outside if your semi local area.

    For the day/night dual. Fly 101nm for 2 hours in the day, eat, return at night and knock that out. But given the 2 hr minimum you might as well go farther and learn more.
     
  33. flyingcheesehead

    flyingcheesehead Touchdown! Greaser!

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    iMooniac
    Yes, And I believe that was the entire point of at least one of the Chief Counsel interpretations of this rule that I've seen - But it was still only when you were going to fly, not just for taxiing to the fuel pump.
     
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  34. dmspilot

    dmspilot En-Route

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    To "come to rest" means "to stop" so I can see where Juliet Hotel was coming from. But your interpretation seems valid also. I just never thought about it before.
     
  35. BrianNC

    BrianNC Pattern Altitude

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    Yeah, makes too much sense.
     
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  36. mtuomi

    mtuomi En-Route

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    dera
    How are those SE go-arounds going for them? Killing many students lately?
    Or do you just cherry pick the standards you use?
     
  37. bflynn

    bflynn Final Approach

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    Bottom line, it’s your log book. Log time however you want, just be ready to explain a 24 hour flight if someone questions it.
     
  38. Greg Bockelman

    Greg Bockelman Administrator Management Council Member

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    Not 100% sure what your point is but there IS such a thing as a Single Engine ATP.
     
  39. mtuomi

    mtuomi En-Route

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    I just tried to make it obvious that "holding to standards of a higher certificate" doesn't really make any sense as a blanket statement. (re. ME commercial but wanting ATP ME standards).
     
  40. Greg Bockelman

    Greg Bockelman Administrator Management Council Member

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    Sigh. Only if you want to apply tasks that aren’t part of a particular certificate. But you CAN apply higher standards to the tasks that ARE required.